State v. Quinn-Ward
341 Or. App. 198
Or. Ct. App.2025Background
- Defendant, Aubrey Ryan Quinn-Ward, was convicted of first-degree online sexual corruption of a child under ORS 163.433 in Washington County, Oregon.
- The charges stemmed from interactions with an undercover officer posing as a 15-year-old named Hannah; Defendant engaged in sexually explicit online communications after learning Hannah’s age.
- Defendant requested sexual photos, discussed bringing condoms, and offered alcohol or marijuana, then traveled to meet at the address provided by "Hannah."
- Some conversations about sexual contact were initiated by the undercover officer, not the defendant.
- At trial, Defendant moved for a judgment of acquittal, arguing insufficient evidence to prove he “solicited” a child for sexual conduct as required by statute.
- The trial court denied the motion; Defendant appealed arguing for a narrower interpretation of “solicit” under the statute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence showed Defendant “solicited” a child under ORS 163.433 | Prosecution argued evidence was sufficient based on explicit requests and offers to meet. | Quinn-Ward argued “solicit” requires affirmatively seeking out, not merely responding. | Court held the evidence was legally sufficient. |
| Statutory interpretation of “solicit” as used in ORS 163.431(5) | Supported interpretation from precedent (State v. Lewis) that "solicit" includes requestive actions. | Quinn-Ward argued that only the initiator of conversations is "soliciting." | Court followed Lewis, finding Defendant solicited. |
| Sufficiency of evidence based on actions taken after knowing age | State argued that Defendant's repeated communications and travel to meet established intent. | Quinn-Ward argued Hannah initiated some conversations, so Defendant was a passive participant. | Court found actions sufficient, regardless of initiator. |
| Impact of previous case law (State v. Lewis) | Cited Lewis to show analogous facts where solicitation was found. | Attempted to distinguish facts, arguing Lewis inapplicable due to conversation initiation. | Court found Lewis controlling and analogous. |
Key Cases Cited
- State v. Lewis, 292 Or App 1 (Or. Ct. App. 2018) (text messages offering to meet for sexual contact constituted solicitation under ORS 163.431(5)).
- State v. Gaines, 346 Or 160 (Or. 2009) (describes Oregon’s rules for statutory interpretation, focusing on text, context, and legislative history).